In a significant order that caught many lawyers in Courtroom No. 7 looking up from their files, the Supreme Court on Monday quashed an FIR accusing Aurangabad-based advocate Samadhan Sitaram Manmothe of rape on the pretext of marriage. The bench of Justice B.V. Nagarathna and Justice R. Mahadevan held that the three-year relationship between the lawyer and the complainant was “clearly consensual” and could not be turned into a criminal case merely because it ended unpleasantly.
Background
The case began in August 2024 when a woman from Chhatrapati Sambhajinagar lodged an FIR accusing Manmothe of repeated sexual assault (Section 376(2)(n) IPC) and criminal intimidation.
The complainant, married and living separately from her husband, had first met the advocate in connection with her maintenance case. Over time, the two developed a close relationship. They met often, exchanged WhatsApp messages, and, as the FIR itself stated, maintained intimacy from March 2022 to May 2024.
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The allegation surfaced only after the lawyer allegedly refused to pay ₹1.5 lakh to the complainant. A chargesheet was later filed, and the Bombay High Court refused to quash the FIR, saying a trial was needed. The matter then reached the Supreme Court.
Court’s Observations
The hearing moved briskly, with Justice Nagarathna repeatedly asking whether the relationship showed any elements of coercion. At one point, the bench observed, “If the complainant herself opposed marriage during the relationship, how can the physical intimacy be attributed to a false promise of marriage?”
The Court noted that the couple’s relationship lasted three years, during which the woman-an adult, educated, and still legally married-met the lawyer entirely of her own choice, including at hotels.
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Referring to earlier rulings, the bench remarked that long-term relationships falling apart cannot be painted as rape unless there is clear evidence of deceit from the very beginning. “A mere break-up cannot trigger criminal prosecution,” the bench said, echoing its recent jurisprudence.
Another point that stood out was the Court’s emphasis on delayed complaint. The last alleged incident occurred in May 2024, but the FIR was filed only in late August. According to the judges, there was “not a whisper” of force or threat in the FIR describing their meetings.
The bench also highlighted a detail from the FIR: when the woman became pregnant in 2022, she had reportedly told the appellant, “You live your life and I will live mine.” This, the Court said, contradicted her later claim that she felt bound by a promise of marriage.
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Decision
After analysing the record, the Supreme Court concluded that the allegations did not disclose rape or any form of sexual violence. The bench declared, “The acts occurred within the contours of a voluntary relationship. Continuing prosecution would be an abuse of the court machinery.”
Accordingly, the Court set aside the Bombay High Court order and quashed FIR No. 294 of 2024 and Chargesheet No. 143 of 2024 pending before the 3rd Judicial Magistrate First Class, Aurangabad.
The appeal was allowed.
Case Title: Samadhan S/o Sitaram Manmothe vs. State of Maharashtra & Anr.
Case No.: Criminal Appeal No. 5001 of 2025
Case Type: Criminal Appeal (Quashing of FIR under Section 376 IPC)
Decision Date: 24 April 2025